QUOTE (Lori H @ Dec 12 2005, 05:43 PM)

generally can a plan rollover annual payments to a term participant over 5 years?
I see no issue, presuming the written plan is not contradicted.
I'm more familiar with an ESOP distributing a note that releases shares of employer securities over 5 years. In this situation, the note is fully taxable in the year of distribution (100% of the benefit), unless the NOTE is timely rolled over.